 | 1999 - 240 pages
...this Convention (including Article 22). ARTICLE 4 — PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which a resident of one of the Contracting States engaged in industrial or commercial activity. (2) The term... | |
 | 2001 - 228 pages
...§514.20 Internal Revenue Service, Treasury ARTICLE 4— PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which a resident of one of the Contracting States engaged in industrial or commercial activity. (2) The term... | |
 | 1998 - 212 pages
...this Convention (including Article 22). ARTICLE 4 — PERMANENT ESTABLISHMENT (1) For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which a resident of one of the Contracting States engaged in industrial or commercial activity. §514.20... | |
 | 1990 - 216 pages
...this Convention (including Article 22). AÏTTŒX 4 — PsajturEiT Ear.» (1) For the purposes of tius Convention, the term 'permanent establishment" means a fixed place of business through whieb a resident of one of the Contracting States engaged m industrial or commercial activity. •... | |
 | United States. Internal Revenue Service - 1968 - 1034 pages
...of this Convention (including Article 22). AKI 1 1 IK 4 PERMANENT ESTABLISHMENT (1) For the pnrposes of this Convention, the term "permanent establishment" means a fixed place of business through which a resident of one of the Contracting States engages in industrial or commercial activity. (2) The term... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1965 - 196 pages
...which are the subject of the present Convention. ARTICLE 3 DEFINITION OF PERMANENT ESTABLISHMENT (1) The term "permanent establishment" means a fixed place of business through which a resident or corporation of one of the Contracting States engages in trade or business. (2) The term... | |
 | United States. Congress. Senate. Foreign Relations - 1967 - 128 pages
...modernized version of the definition found in most conventions to which the United States is a party. The term "permanent establishment" means "a fixed place of business through which a resident or corporation of one of the Contracting States engages in trade or business". Illustrations... | |
 | United States. Congress. Senate. Foreign Relations - 1968 - 80 pages
...convention. The new definition is taken from the OECD model convention except as noted below. As modified the term " permanent establishment" means "a fixed place of business through which a resident of one of the Contracting States engages in industrial or commercial activity." Illustrations... | |
 | United States. Internal Revenue Service - 1971 - 816 pages
...as compensation for personal services either as an employee or in an independent capacity. ARTICLE 9 PERMANENT ESTABLISHMENT 1. For the purpose of this...establishment" means a fixed place of business through which a resident of one of the Contracting States engages in industrial or commercial activity. 2. The term... | |
 | United States. Internal Revenue Service - 1976 - 624 pages
...articles shall, except as otherwise provided therein, supersede the provisions of this article. Article 9. Permanent Establishment. ( 1 ) For the purpose of...establishment" means a fixed place of business through which industrial or commercial activity is carried on. (2) The term "fixed place of business" includes but... | |
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permanent establishment' means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term 'permanent establishment... 
